1. POLICY PURPOSE

• telMAX (“telMAX”, “we”, “us”, “our”, or the “Company”) is committed to protecting the privacy and security of personal information it handles in the course of its business, and ensuring its ongoing compliance with applicable privacy laws. This Privacy Policy (the “Policy”) describes how telMAX collects, uses, discloses and protects personal information.
• This Policy describes what personal information we may collect from or about you, why we use your personal information, how we may share personal information with third parties, and more generally the information handling practices we maintain.
• By providing your personal information to us, you acknowledge that we may use and disclose it as set out in this Policy. We may provide you with further notices highlighting certain uses we wish to make of your personal information. We may also give you the opportunity to opt-in or opt-out of selected uses, such as marketing, when we collect your personal information, in each case in accordance with applicable law.

2. SCOPE AND DEFINITIONS

• This Policy applies to the Company’s management of personal information in any form, including electronic, written, oral, or presented on a website or social media platform. This Policy applies, without limitation, to all information provided by customers, users of telMAX’s website at http://www.telmax.com or anyone else who communicates with us. It also applies to data collected on location (e.g., security cameras at telMAX locations) or otherwise in connection with our services.
• This Policy does not apply to job applicants, employees, contractors or other team members. If you are an employee, contractor or other team member of the Company, please contact your hiring contact, manager or a member of the People Operations team if you have any questions about how your personal information is handled.
• Within this Policy,
  • “personal information” refers to any factual or subjective information about an identifiable individual. Personal information does not include aggregated or anonymized information that cannot reasonably be associated with a specific individual.
  • “Services” means our internet, TV and streaming, home phone, customer support and other related services.

3. HOW DO WE COLLECT PERSONAL INFORMATION?

• Depending on how you interact with us, we may collect your personal information using the following means:
  • When you provide the information directly, such as through our website forms or by phone, email or chat.
  • Via cookies and other similar tracking technologies deployed on our website.
  • From other individuals, such as roommates or family members who have registered you for our Services on your behalf.
  • We may collect information about you from other sources, such as publicly available information. We will either seek your consent or obtain the information as permitted or required by law.
• We may also request personal information about third parties from you. Before you provide personal information about someone else, you must ensure that this Policy has been drawn to the attention of those individuals and you have consent to share their personal information with us so that we use and handle it as described in this Policy.

4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW IS IT USED?

• The Company strives to only collect and process the personal information needed to fulfill legitimate identified business purposes.
• We may collect, use and disclose various types of personal information, depending on how you interact with us:
  • Registration. If you register for our Services, we will collect basic subscriber information, including list subscriber information, e.g., name, email address, phone number, physical address, password, plan type, purchase history, installation request details (as applicable) and preferences. We use this information to establish and manage the customer account and relationship, install any equipment you purchase (as applicable), provide you with our Services, and communicate with you in connection with the Services (e.g., to arrange for the installation of equipment, provide notifications regarding service changes or billing issues, responding to technical support inquiries, etc.). We may also ask you to provide a password which we use to authenticate you.

• • Billing. When you make a purchase with us, we will ask for billing information such as billing address, debit/credit card or bank account information. In certain circumstances, you may provide this information to our third-party payment processor. We or our provider may use this information to process payments and for related purposes (including fraud detection, record keeping, and to protect legal interests).

• • Network Management. telMAX collects limited network information from devices to provide our Services and for analytical and troubleshooting purposes, such as analyzing wi-fi issues, and to perform remote management. These activities will not expose any customer traffic or content. This networking information includes device information such as device IP address, MAC address, and other device information necessary to provide you with internet and phone service.
  • Network Security and Law Enforcement Requests. We may monitor network service activity of our Service users for network integrity, security or for monitoring compliance with our relevant agreements. We may at any time be legally required to monitor or record and preserve evidence of the activities of identified customers or may be required to remove content in whole or in part as a result of court orders and/or warrants or statutes, without prior or subsequent notice provided to you. We also keep records of certain user traffic such as URLs of sites visited, length of time connected, metadata and data transmission information. This information is not accessed or used, except when required to respond to a warrant, court order or similar legal requirement.

• Marketing Communications. If you subscribe to our marketing messages we may collect your full name, email address, phone number and communication preferences. We use this information to send you newsletters, promotions, surveys or other relevant materials in accordance with your preferences. You may unsubscribe to our promotional emails at any time by clicking the unsubscribe button in any promotional email to you.

• • Communications. You may contact telMAX on different channels (call centre or chat, for example) for support or information. We will use the information you share primarily to respond to your queries or otherwise provide you with customer support. Please note that telMAX may record such interactions for training and analytics purposes in which case you will be notified in accordance with applicable privacy laws. In some cases, artificial intelligence may be used to expedite or analyze interactions with support representatives.
  • Analytics Services. We use analytics providers, such as Google Analytics, to collect and analyze information about how visitors use our website, including device and usage data such as IP address, general location, browser type, pages visited, referral source, and time spent on our website. This information is provided to us in aggregated and anonymized form, which we use for website personalization, support, and to improve our website content and user experience. The analytics tools may place cookies on your device, but you may opt out of receiving cookies through your browser settings, by installing the Google Analytics Opt-out Browser Add-on. This information is processed in accordance with Google’s privacy policy.
  • Security Cameras. telMAX uses security cameras at certain of its physical locations, including facilities where our network infrastructure is housed. These cameras capture video footage for the purposes of protecting the safety and security of our employees, visitors, equipment, and property, as well as for the prevention and detection of unauthorized access, theft, or other security incidents.
  • Anonymized Data. We also use customer information on an aggregated, anonymized basis to develop, market, and provide products and services to customers, for statistical analysis and research and for other purposes in accordance with applicable law.

5. ADDITIONAL PURPOSES FOR PROCESSING PERSONAL INFORMATION

• In addition to the specific purposes outlined above, telMAX may also use personal information for additional purposes as appropriate. These purposes include:
  • To understand the needs and preferences of our customers, determine your eligibility for products and services, and recommend product or services to meet your needs (with your consent where required by law);
  • to ensure compliance with legal and regulatory requirements;
  • for security and fraud detection and prevention purposes;
  • to maintain the health, safety, and security of the public, our customers, employees, and property;
  • to defend legal claims or otherwise protect our legal interests or the legal interests of third parties; and
  • otherwise with your consent, or as permitted or required by law.

6. HOW DO WE SHARE PERSONAL INFORMATION?

• We may share personal information with various third parties, including:
  • Cloud Software or Storage Providers. Our cloud software or storage platform providers may have access to personal information we collect, to provide and maintain our software and cloud storage systems (e.g., website platform providers, communications platforms, customer databases, service software, etc.).
  • Payment Processors. We use third-party payment processors to manage payment card processing. These processors may collect, use and store your billing information to process payments and for related purposes in accordance with their privacy policy (e.g., fraud detection, record keeping, and to protect legal interests).
  • Technicians. We may share your address, plan details and contact information with our service technicians who may assist in installing or troubleshooting our products.
  • Third Party Tracking Technology Providers. We use third-party cookie providers to enhance your browsing experience and collect information about how you interact with our website. These cookies allow us to analyze how people navigate our websites in order to understand and track the effectiveness of advertisements placed on other websites, and send retargeted advertising. You can manage your cookie preferences through your browser settings.
  • Advertising Platforms. With your consent, we share a hashed (scrambled) version of your email address with ad platforms such as Meta and Google. They match it against their own users so we can stop showing you ads for a service you already have, make our ads more relevant, and see which campaigns work. Nothing that identifies you comes back to us. These platforms may also use the match for their own advertising and to personalize features and content. To withdraw consent, email privacy@telmax.com.
  • Telephone Companies. We may share personal information with another telephone company where the information is required for the efficient and cost-effective provision of telephone service, provided that such disclosure is made on a confidential basis and the information is used only for that purpose.
  • Collection and Administrative Agents. We may share personal information with agents retained by us in the collection of your account or to perform other administrative functions on our behalf, provided the information is required for and used only for that purpose. These may include website maintenance providers, customer service providers, data processing providers, security camera system providers, or mail distribution providers].
  • Law Enforcement. We may disclose personal information to a law enforcement agency where we have reasonable grounds to believe that a service user has knowingly supplied us with false or misleading information or are otherwise involved in unlawful activities.
  • Public Authorities. We may disclose personal information to a public authority or agent of a public authority if, in our reasonable judgment, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information (e.g., public emergencies).
• Please note that we may change or add third party service providers at any time, in our sole discretion. We encourage you to review our privacy policy from time-to-time to obtain updated information about our service providers.
• Subject to applicable law, we may also disclose your personal information to third parties in connection with loans or other financing that we seek or in connection with a prospective or completed business transaction, including a merger, sale or transfer involving all or part of Company or its assets or as part of a reorganization or restructuring or other change in legal form or corporate control.
• We may disclose personal information to comply with the law. For example, we may be compelled by legal action to release information in connection with statutory reporting obligations, search warrants, court orders, subpoenas, summons, discovery obligations, bankruptcy or insolvency proceedings or other legal requests.
• We may disclose your personal information to an individual who, in our reasonable judgement, is acting on your behalf, such as through a valid power of attorney or other written authorization.
• We may also disclose personal information to other parties where you consent or when otherwise permitted or required by law.
• Please note, some of the third parties listed above may process or store your personal information outside of Canada, including in the United States. Personal information that is processed outside of Canada may be accessible to foreign courts, law enforcement and national security authorities.

7. CHILDREN

• We do not knowingly collect personal information from children. To purchase or use our Services, individuals who are under the age of majority in their province of residence must obtain the consent of a parent or legal guardian.
• If we learn that we have collected or received personal information from a child without parental consent, we will take steps to delete that information. If you believe we may have collected any information from or about a child, please contact us.

8. HOW IS YOUR PERSONAL INFORMATION PROTECTED AND HOW LONG IS IT STORED?

• telMAX has implemented and will maintain appropriate physical, technical, and organizational security measures designed to secure personal information against accidental loss and unauthorized access, use, alteration, or disclosure.

• However, the transmission or storage of personal information via the internet or other electronic means is not completely secure. Therefore, we cannot guarantee the security of your personal information. Any transfer or storage is at your own risk to the extent permitted by applicable law.
• If you are suspicious of any telephone, mail or email promotional campaigns received from us, or you suspect fraudulent activity related to one of your accounts, please contact us.
• We strive to only retain your personal information for as long as it is necessary to fulfill our purposes or satisfy legal requirements. When personal information is no longer needed for our legitimate business purposes or to comply with legal retention requirements, we will securely destroy or anonymize the personal information.

9. MAINTAINING ACCURACY

• We take reasonable steps to keep your personal information accurate and complete, and you may request a correction by contacting us as set out in the Your Privacy Rights section below.

10. THIRD PARTY LINKS

• Our website and advertisements may link to third-party websites whose privacy practices differ from ours, and we are not responsible for their content or practices.

11. YOUR PRIVACY RIGHTS

• You may have various privacy rights available to you depending on where you are located. These rights are subject to restrictions and limitations under applicable laws. These rights may include:
• You may access your personal information that has been retained by the Company.
• You may challenge the accuracy and completeness of your personal information, and have it updated or amended as appropriate. We will correct or complete any personal information that a customer has identified as being inaccurate.
• Withdrawing Consent. You may withdraw consent to the continued collection, use or disclosure of your personal information, subject to reasonable notice and other legal or contractual limitations. Please note, withdrawing consent may impact the availability of certain Services or website features.
• Unsubscribing. You may unsubscribe to our marketing emails at any time by clicking the unsubscribe button in any email to you, or by contacting us as set out below.
• You may also submit any concerns regarding our privacy program. We will record all complaints and details, acknowledge receipt, and ensure the complaint is investigated in a timely manner in accordance with applicable laws.
• You may exercise your privacy rights described above by contacting us as set out below. Please note that we may need to verify your identity prior to carrying out your request.

12. CONTACT US

• Our Privacy Officer oversees compliance with this Policy and applicable privacy laws. To exercise your privacy rights, or if you have any questions about this Policy, you may contact the Privacy Officer by emailing privacy@telmax.com.

13. CHANGES TO THIS POLICY

• This Policy will be reviewed from time to time to reflect changes in legal or regulatory obligations, or to reflect changes in best practices for managing personal information. Updated versions will be available on our websites. By continuing to use our Services or visit our website, individuals agree that their personal information will be managed under the current Policy. Where required by law, we may reach out directly to inform you of changes.